Which TTB Label Changes Do Not Require a COLA?

If your product is in need of an aesthetic change, it’s important to brush up on the rules governing alcohol labels by the Alcohol & Tobacco Tax & Trade Bureau (or “TTB”). Those familiar with the Certificate of Label Approval (“COLA”) process likely know how tedious the alcohol label process can be. What some industry members may not know is that TTB allows for certain revisions and changes to alcohol labels without submitting a new COLA.

There are several changes listed on TTB’s website (click here for a full list) which do not require a COLA, however some of the more common ones include changes to graphics of the label (such as color, design, font, and illustrations), repositioning of labels or changes of the label shapes, and deleting non-mandatory label information (such as text, illustrations, and graphics). TTB allows for other changes without approval so long as the changes comply with applicable regulations and tax designations.

Notwithstanding the above, many label changes do require a new COLA. These changes include the following:

  • Class/type statements

  • Brand name changes

  • Changes to appellations of origin (only applies to wine)

  • Changing the mandatory address statement (unless the new address is in the same state as the old address)

  • Changes to the actual bottler or importer information

  • Adding new graphics/pictures/representations (except as specifically authorized, for example, holiday themed graphics)

  • Adding new wording/phrases/text/certifications (except as specifically authorized, for example serving instructions)

If you are considering changes to your beer, wine, cider, or distilled spirits labels, we recommend speaking with an experienced TTB consultant.

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